ML20245D351
| ML20245D351 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/02/1989 |
| From: | Gloersen W, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245D341 | List: |
| References | |
| 50-338-89-15, 50-339-89-15, NUDOCS 8906270080 | |
| Download: ML20245D351 (19) | |
See also: IR 05000338/1989015
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Repo.rt Nos a . 50-338/89-15 and 50-339/89-15'
Licensee: Virginia Electric and Power Company.
. Glen Allen, VA 23060
Doc'ket'Nos.: 50-338 and 50-339'
Licer.se Nos.: NPF-4 and'NPF-7
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Facility Name: North' Anna 1 and:2
. Inspection Conducted: May 1-5, 1989
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Inspectors
h-6 M
$31/6'l
W. B. Gloersdn ' V
Date Signed
b<AhAnbdD
r/si/91
R. B 05 rtr'
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Date igned
Approved by:
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J.7. - Potter, Chief
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Date Signed
racilities and Radiation Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unann'ounced inspection cf the licensee's radiation ~ protection
program consisted of a review'in the areas of external and internal exposure
control; control of radioactive material and contamination, surveys, and
monitoring; and the program to maintain. doses as low as reasonably achievable
.(ALARA).
The inspection also involved observations of health physics job
coverage during the dual unit outage.
Results:
'In the ' areas inspected, one violation (with two examples) was identified for
ifailure to make an adequate survey (Paragraph 3.b.).
Of particular concern was
the apparent lack of timely implementation of the corrective action for the
violation 'which occurred on April 9, 1989.
In general, the licensee's .
radiation protection program appeared to be functioning as necessary to protect
the health and safety of the occupational radiation workers.
However, it
appears that the station's 1989 annual collective dose will significantly
exceed its 1989 projected collective dose.
Contributing factors to the high
collective dose included (1) extended simultaneous dual unit outages; (2) large
core snubber removal; and (3) removal and replacement of steam generator tube
plugs.
As of April 30, 1989, the station's collective dose was approximately
8906270080 8906'15
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ADOCK 05000338
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824 person-rem which represented appropriately 83 percent of the 1989 budgeted
collective dose (994 person-rem).
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REPORT DETAILS
1.
Persons Contacted
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Licensee Employees
J. Atkins, Health Physics Trainee
- M. Bowling, Assistant Station Manager, Nuclear Safety and Licensing
E. Dreyer, Supervisor, Technical Services, Health Physics
- R. Driscoll, Manager, Quality Assurance
R. Enfinger, Assistant Station Manager, Operations and Maintenance
R. Irwin, Supervisor, Operations, Health Physics
T. Johnson, ALARA Coordinator, Health Physics
- P. Kemp, Supervisor, Licensing
- J. Leberstein, Licensing Specialist, Licensing
N. Nicholson, Staff Health Physicist
J. O'Connell, Shift Supervisor, Health Physics
T. Peters, Assistant Supervisor, Dose Control and Bioassay, Health Physics
'A. Stafford, Superintendent, Health Physics
- W. Thornton, Director, Health Physics and Chemistry, Corporate
- F. Wolking, Senior Staff Health Physicist, Corporate
Other licensee employees contacted during this inspection included
craftsmen, engineers, operators, mechanics, and technicians.
Nuclear Regulatory Commission
- J. Munro, Resident inspector
- Attended exit interview
2.
Organization and Management Controls (83750)
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a.
Organization
The liransee is required by Technical Specification (TS) 6.2 to
implement the plant organization specified in TS Figures 6.2-1.
The
responsibilities, authority and other management controls were
further outlined in Chapters 12 and 13 of the Final Safety Analysis
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Report (FSAR).
TS 6.2 also specified the members of the Station
Nuclear Safety and Operating Committee (SNSOC) and outlined its
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function and authority.
Regulatory Guide 8.8 specified certain
functions and responsibilities to be assigned to the Radiation
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Protection Manager and radiation protection responsibilities to be
assigned to line management.
The inspector reviewed the licensee's station health physics (HP)
organization.
No significant changes to the organization had taken
place since the last inspection other than the permanent assignment
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to the position of HP Supervisor (Radiological Engineering).
There
appeared to be adequate management support to implement essential
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elements of the radiation protection program.as necessary.
b.
Menagement Controls
The inspectors reviewed.various reports, including Radiation Problem
Reports, Personnel Contamination Events
Station Deviation Reports,
and thermoluminescent (TLD) vs. self-reading dosimeter (SRD)
discrepancy reports, which wculd provide information on program
quality.
The licensee's Radiation Problem Reports (RPRs) were used
to identify and document safety and radiological problems noted by HP
personnel in the p' ant.
One RPR dealt with an administrative
overexposure which is discussed further in Paragraph 3.b.
Most of
the other problems identified in these RPRs were concerned with
compliance of personnel with various procedural or radiation work-
permit (RWP) requirements.
A few of the RPRs identified problems
with advanced radiation workers collecting air samples in accordance
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with RWP requirements. The inspectors observed that the licensee did
not have a system to track and identify trends in the RPRs.
The
inspectors also made the same observation regarding Personnel
Contamination Events (PCEs) and TLD vs. SRD discrepancies.
Additionally, the inspectors noted that the licensee collected
information on maintenance rework activities; however, there was no
system in place to identify or trend the rework activities that
involved significant dose.
The licensee agreed to review and
consider developing a system to track and identify trends in the
areas of RPRs, PCEs, TLD vs. SRD discrepancy reports, and maintenance
rework activities.
The inspectors indicated that
his area of
tracking and trending would be reviewed in a subsequent inspection
and would be tracked by the NRC as an Inspector Follow-up Item (IFI)
(50-338/89-15-01).
3.
External Exposure Control and Personnel Dosimetry (83750)
a.
Personnel Dosimetry
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and requires the use of
such equipment.
During a previous radiation protection inspection
(50-338/89-05 and 50-339/89-05), the practice of wearing paper
coveralls over the plastic bag containing an individual's SRD, which
was normally -orn attached to a loop on the outside of the cloth
protective clothes (PCs), was identified.
This practice would
inhibit individuals from checking SRDs frequently in order to keep
their exposures as low as reasonably achievable (ALARA).
During this
inspection, it was observed that the licensee had begun the practice
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of wearing the plastic bag containing the SRD outside the paper
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coveralls by piercing a small hole in the paper coverall so that the
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tie-ons on the plastic bag could be easily inserted through the hole
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and attached to the loop on the outside of the cloth PCs.
During
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tours of the Unit 1 containment,'the inspectors observed that three
individuals did not have their SRDs outside of their paper suits
- while entering Unit I containment.
The licensee was made aware of
'this problem.
-The ' inspectors also reviewed TLD vs. SRD correlation error reports
for 1989.
HP procedure HP-5.1.30, Dosimetry Processing and Dose
Determination, dated December 22, 1988, described the correlation
error reporting methods.
The correlation error reporting criteria
were as follows:
(1) if either the TLD or SRD total exceed
100 millirem (mrem) and the correlation error exceeds 30 percent (%)
(% correlation error = [(TLD-SRD)/TLD] x 100%), then a correlation
report would be generated; and (2) if either the TLD or SRD total
exceeded 300 mrem and the correlation error exceeded 30%, then the
individual would not be allowed to re-enter the radiologically
controlled area -(RCA) until either the correlation error is resolved
or until authorized by the HP Superintendent. The inspectors did not
observe any " criterion 2" type correlation errors.
The inspectors
noted that during the month of April 1989, over 100 correlation error
reports were generated.
In or,e case, the TLD dose was approximately
47% greater than the SRD dose (191 mrem vs. 130 mrem). After it was
determined that the TLD tested satisfactorily, the TLD dose was
assigned t
the individual.
During the correlation error report
review, the inspectors observed that the reports were stored in a
cardboard box in no apparent chronological order.
There was no
attempt made to track the number or trend the type of correlation
errors.
These reports were usually discarded at the end of each
quarter.
For further information regarding the tracking and trending
of these reports, the reader should refer to the Paragraph 2.b. of
this report.
The inspectors reviewed the quarterly collective TLD
and SRD dose correlation from first quarter 1988 through first
quarter 1989.
During that time period, the SRD collective dose
ranged from 24% to 4% greater than the TLD collective dose.
The inspectors also reviewed personnel doses for calendar year 1989
and noted that as of May 2, 1989, three individuals had accumulated
over three rem.
All three individuals were maintenance contractors.
The highest individual doce as of May 2,1989, was 3.862 rem. None
of these individuals exceeded 3 rems for the first quarter 1989.
It
was determined that the licensee satisfied the requirements of
10 CFR 20.101(b) which allows the licensee to permit an individual in
a restricted area to receive a total occupational dose to the whole
body greater than 1.25 rems per calendar quarter, provided that the
provisions in 10 CFR 20.101(b)(1), (2), and (3) are met.
b.
Control of High Radiation Areas
10 LFR 20.201(b) states that each licensee shall make or cause to be
made such surveys as (1) may be necessary for the licensee to comply
with regulations in this part, and (2) are reasonable under the
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circumstances to evaluate the extent of radiation hazards that may be
present.
.The inspectors reviewed licensee investigation documentation for two
events that resulted in personnel receiving an inadvertent dose in
excess of the administrative control values to radiation.
Both of
these events were identified by the licensee.
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On April 9,1989, a crew of mechanics were assigned to replace the
packing in two valves (2-RC-81 and 2-RC-101) located in different
areas in the Unit 2 "C" loop room.
RWP-89-1786 indicated radiation
levels of 300 t'
600 mR/hr general area (12 inches) and a 2,000 mR/hr
hot spot on contact with valve 2-RC-81.
In addition, a full set of
protective clothing was required with full face respirator, TLD and
SRDs affixed on the workers' head, hands and elbows.
Contamination
levels were up to 78, 30 dpm/100 cm2 and the workers were required to
wear wet suits to protect against hot particle absorption.
One
mechanic unbolted the packing gland on 2-RC-101 in approximately
eight minutes and received 30 mrem on his " head SRD."
The same
mechanic unbolted the packing gland on 2-RC-81 in approximately eight
minutes and received 65 mrem to the head dosimeter.
Only the head
dosimeter was monitored by the ^HP technician because all other
dosimetry was worn under the wet suits.
Based on these operations,
the HP technician calculated stay times for the other workers at
approximately 12 minutes. A second mechanic removed the packing from
both valves in 10 minutes and picked up less radiation than the first
worker.
The HP technician then allowed two mechanics to install the packing
on both valves at the same time.
The licensee's report stated that
this diluted the HP technician's coverage of work on valve 2-RC-81.
The mechanic, in repairing 2-RC-81, had to lie down on the grating to
properly install the packing, whereas the two mechanics that
previously worked the valve remained in the squatting position during
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the repair.
The final worker, who received the unplanned exposure, was tasked
with final assembly of the packing gland and torquing of the packing
nuts in accordance with approved procedures.
To gain the required
position, this mechanic also laid on the grating with his right elbow
near the plane of highest radiation. The Virginia Electric and Power
quarterly whole body exposure control point of 750 mrem was exceeded
when the mechanic received 545 mrem for this job. The individual had
received 300 mrem prior to the operation which, when added to this
operation, resulted in 845 mrem for the quarter.
In discussions with
the inspectors, licensee representatives stated that the exact time
spent by the mechanic in the area was not determined but difficulties
were experienced in installation of the split ring on the gland and
in installation of the strongback during repacking and torquing.
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Licensee representatives identified in the investigation the
following points:
(1) The HP contractor technician did not fully understand the
administrative controls on exposure imposed by the licensee.
(2) Zone coverage of jobs with high potential for unplanned exposure
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should not be encouraged by workers and that HP technicians
should not direct their attention away from the worker in these
circumstances.
(3) The source term was not fully understood as related to the
workers body configuration with respect to the job.
(4) The HP covering the job did not have sufficient dosimetry to
comfortably cover the job and did not halt work to obtain needed
equipment.
Licensee representatives concluded as a result of the investigation
that the focus of the workers was on completing the job quickly, that
the HP contract technician was not prepared to cover the job, covered
too much work at once, and did not devote enough attention to the
job.
In addition, the pre-job survey did not precisely determine the
dose-retes.
According to the licensee, the root cause of the event was lack of
understanding the source term.
The short term corrective action was
to discuss the administrative exposure limits and emphasize closer
control on work activities with the technician.
Long term corrective
action stated that administrative control values will be discussed
with all contract HP technicians.
The inspectors were not able to obtain training material from the
licensee that verified that the long term corrective action had been
performed.
The inspectors, in interviews with a licensee HP
supervisor, determined that only the HP personnel involved in the
event had received any type of briefing regarding corrective actions,
not all contract personnel as stated in the deviation report. During
the inspection, the inspectors informed licensee management that the
corrective actions did not address all problems identified during the
event and that, as a result, the corrective action identified was not
adequate to prevent recurrence, nor was the long term corrective
actian completed as stated. The inspector informed the licensee that
t'iis would be considered as a licensee-identified violation (LIV) but
would not be cited.
Upon evaluation at Region II, this event was
reclassified as the first example of an apparent violation of
10 CFR 20.201(b) and TS 6.8.1 (50-338, 339/89-15-02).
The second unplanned exposure occurred on May 1,
1989, and
involved a maintenance foreman who received 1,640 mrem to his left
thigh during the repair of the fuel transfer cart in the Unit 1
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. transfer canal.
Day: and night shift crews of mechanics made several
entries on RWP-89-2-2074 to replace bushings on eight of the sixteen
wheels on theLtransfer cart. The 'RWP listed general area dose rates-
vas 200.to 14,000 mR/hr. and a contact, hot spot reading of 80 R/hr.
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Contamination levels were listed as up' to.1,000,000 dpm/100 cme and
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the' area was considered a hot particle area:so disposable coveralls
(paper suits)'were required.
Full. face respirators and.multibadging
was also required.- An entry to repair the transfer cart at 0300
hours ' on. May 1,1989, was planned and a preshift briefine was
, conducted.
During the briefing, the HP technicians and workers
discussed a~ 200.R/hr. hot spot and general. area radiation levels.of .
-20 to. 25 R/hr at. one foot.
During this and previous entries, a
teledose system was used.
The worker wore en electronic integrating
' dosimeter that sent a readout signal to a receiver / monitor at a
remote location from the job site.
Head set communications between
the workers and personnel at the monitor were planned.
The HP ~ contract. technician and crew ertered the area and the HP
technician took_ surveys when the mechanic was in position to repair
the transfer cart.
The technician identified highly localized,
non-uniform dose rates and made the worker reorient his body to the
job as dose rates to the head were unacceptable.
The HP technician
resurveyed around the perimeter of the worker's body and noted that
dose rates were acceptable.
Since the cable was not long enough fnr
the headset / monitor connection, headset communication between the
worker - (251 foot (ft) elevation) and teledose/ monitor (292 ft
elevation) was not possibic.
Hence, the headset was placed at the
262.ft elevation.
The HP technician left the transfer canal and
proceeded' to. the 262 ft elevation to don the headset 'for
communicating with the 292 ft. elevation.
During transit to the
262 ft elevation, the teledose/ monitor received an alarm.
The'HP
technician that had not yet reached the ~ 262 ft elevation was
dispatched to remove the worker from the transfer cart work area.
The licensee estimated thtt approximately 40 seconds had elapsed when
the HP technician left the job site and returned to retrieve the
worker.
The licensee established that, during this time, the worker
shifted the position of his body to the job causing the teledose to
receive an alarm at a . 275 mrem set point.
However, the foreman,
during an informal mockup later to determine his position to the
source, stated that when he shifted his position just before the
teledose alarmed, he still maintained the original orientation to the
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job.
The HP contract technician returned to the transfer canal job site
for a follow-up survey and located an 800 R/hr hot spot contact
reading in the fuel basket.
The teledose units were source checked
and verified operable before and after the job and two follow-up
surveys were conducted to verify the 800 R/hr reading.
The first
follow-up survey did not identify the source but the second survey
did.
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The licensee's evaluation of the' event identified the following as
contributing factors:
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(1) Poor job planning
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(a) Poor communications between maintenance and HP led to poor
understanding of jou site activities and radiological
conditions.
(b) Inadequate survey of the fuel transfer cart and fuel basket
because of incomplete understanding of the exact job site.
A survey for the transfer canal blank flange elevation was
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used for the RWP
(c) No craft procedure was available for the high dose, high
radiological risk environment.
(d) No evaluation of the worker's position relative to the
source was made during the planning stage.
In this case of
ren *;niform, highly localized doses, an evaluation of
right-handed versus left-handed orientations would have had
a significant ALARA impact.
(e) Poor work practices compromised the integrity of mechanical
components.
Shif t turnover ~ between maintenance crews
information appeared to be poorly documented.
(2) Delayed worker response to the alarming teledose unit.
The
worker did not immediately step away from the job site when the
teledose alarmed.
(3) Poor communication system between the HP technicians and the
workers.
(4) Schedu1?79 constraints to cor.plete the job in a timely fashion.
The licensee made recommendations to prevent recurrence in the
investigative report; however the inspectors noted that the report
was not clear in identifying details for all contributing factors
listed.
The inspectors noted that the licensee had not identified
short term or long term corrective actions and that the investigative
report had no, been finalized at the time of the inspection.
The inspectors informed licensee representatives and licensee
management during the exit interview that the second unplanned
exposure, where the mechanic received a dose of 1,640 mrem to his
lef; thigh, was considered to have safety significance and had the
potenti;l for an exposure above regulatory limits.
Also, it was
apparent that the quick recovery of the individual from the work area
when the teledose alarmed resulted in not exceeding a regulatory dose
limit.
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During the inspection, the inspectors identified the following
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similarities in both events to licensee representatives and informed
the licensee that' adequate and timely corrective action may have
prevented the second administrative overexposure event:
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(1) Radiation surveys performed for the RWP and by the contract
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health physics technicians during the job were inadequate to
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identify the extent of the radiation hazards present.
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(2) Poor communications identified in both events.
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(3) Attention of the HP technician covering the job was not always
directed at the job / worker.
(4) On both jobs, a change in the individual's orientation to the
source was considered a factor.
(5) Inadequate dosimetry in the first event and inadequate response
by the worker to dosimetry in the second event. The inspectors
noted that for both jobs disposable coveralls or wet suits
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covered dosimetry that should have been exposed and visible to
the worker or HP technician covering the job.
This was
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previously pointed out to the licensee in inspection report
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50-338, 339/89-05,
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The inspectors informed licensee management that failure of HP
personnel to perform a radiation survey sufficient to identify the
extent of the radiation hazard present was the second example of an
apparelt violation of 10 CFR 20.201(b) and TS 6.8.1 (50-338,
339/89-15-02).
c.
Radiation Work Permits
The inspectors observed work being performed under the control of
RWPs and verified that the applicable requirements of the RWPs were
met,
d,
Control of Radiation Areas
During tours of RCAs, the inspectors reviewed the licensee's posting
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and control of radiation, airborne radioactivity, contaminated and
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radioactive material areas.
The inspectors performed independent
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radiological surveys throughout the RCA of the plant and verified
that the radiation levels were consistent with area postings.
The
inspectors identified a reading of 90 mR/hr. at 12 inches from the
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Evaporator Demineralized, lower level of the Auxiliary Building.
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department personnel verified the reading.
Since the demineralized
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was in operation, HP conservatively posted the area as a high
radiation area.
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-Internal Exposure Control and Assessment (83750)
a.
Engineering Controls
10 CFR 20.103(b) requires the licensee to use process or other
engineering controls to the extent practical to limit concentrations
of radioactive material in air to levels below those specified in
10 CFR Part 20, Appendix B. Table 1, Column 1.
During tours of. the Auxiliary Building and the Unit 1 Containment,
the inspector observed various engineering controls to limit the
concentration of airborne radioactive material.
These included the
use of ventilation systems equipped with high efficiency particulate
air (HEPA) filters and containment enclosures.
The licensee used
tent enclosures and vendor supplied sealed chambers to decontaminate
various tools and items of equipment and to perform maintenance on
some contaminated items.
b.
Internal Assessment
The licensee's whole body counting equipment consisted of two Nuclear
Data " bed" geometry systems (ND100 and ND6620) which were located in
the dose control and bioassay field office located outside of the
protected area.
The inspectors reviewed selected whole body count
results for calendar year 1989, and observed that no administrative
limits had been exceeded.
The licensee's administrative limit, as
defined in HP-5.2 B.11, Bioassay Data Evaluation and Follow-up, dated
October 1, 1985, is a body burden of 5% of the maximum permissible
body burden (MPBB).
The inspectors also reviewed selected airborne
radioactivity area entry logs for calendar year 1989, and noted that
on March 13, 1989, 15 individuals were apparently exposed to greater
than 2 MPC-brs in one day while working on lifting the Unit 2 upper
internals.
However, no individual during that time period had been
exposed to 10 MPC-hrs in any seven days. The MPC-hr assignments were
based on calculations derived from an air sample collected in the
area of the 291 ft level on the refueling floor and not in the
breathing air zone.
The licensee recognized this problem, collected
additional air samples, obtained whole body counts on all individuals
involved with the upper internals lift, and discussed with
technicians the proper technique in collecting a breathing zone air
sample.
The additional air samples that were collected were below
10% of MPC except for one nir sample which was 38% of MPC,
As
mentioned earlier, all whole body counts of the individuals were less
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than the minimum detectable activity of the counting system.
Additionally, the inspectors reviewed Deviation Report #B7-1073 which
described an event involving a greater than 40 MPC-hours inhalation
of Co-58 and Co-60.
The report provided a description of the
incident, description of the location and circumstances, chronology
of events, cause of the incident, radiological evaluation, and the
corrective actions. The event occurred on September 17, 1987, when a
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contract Senior HP Technician was inttructed to survey the intake of
the Process Vent' Filter (1-GW-FL-18) housing, located.on the 274 ft
level .of: the Auxiliary Building for a- radiation hot spot causing
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Approximately 700 mR/hr. contact dose rate. . The technician's goal
was to locate. and possibly remove .the radioactive material causing
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the hot-spot.
Based 'on survey results, it was assumed that the hot
spot was a point source, possibly a.small piece of; resin.
The technician was able to localize a spot.inside the housing reading
800 mR/hr-(contact) using a closed window on an R0-2.
To reach the
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. spot.and. read the mater.with a flashlight, the technician had to' lean
inside the filter housing. The technician attempted to wipe away the
materia 12 causing the hot spot with masslinn.
Upon finding that the=
masslinn cloth,was covered with fine black dust. reading 1200 -(open)
and:150 (closed) mR/hr on an R0-2, the techt.ician suspected an-intake
of radioactive: material.
The technician frisked his nose and mouth
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area. and observed 200 ' counts above background.
A whole' body count
was subsequently performed and an intake of 255 nanocuries (nCi)
C0-58 and 66.6 nCi Co-60 was confirmed.
The technician was barred
from entering the RCA,. scheduled for daily whole body counts, and
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requested to supply a urine sample.
Based on a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> retention
period after- the intake, the technician was assigned the following
bioassay.results:
0.71%
MPBB
6.74%
maximum permissible organ burden (MP0B)-
41.38
MPC-hours
The activity was eliminated from the body with an average effective
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halflife of 3.7 days..
On September 25, 1987, whole body count
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results indicated less than 5% MP0B.
On October 1,1987, the
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technician's whole body count result showed less- than 1% MP0B.
The
presence of Co-58 and'Co-60 was confirmed by gamma isotopic analysis
- of the mass 11n.
Mn-54 and Nb-59 were also present; however, the
quantities present were less than 3% of the total.
The Co-58/Co-60
ratio as determined by the whole body count results agreed favorably
with the gamma isotopic results.
The urinalysis results generally
' agreed with the whole body count results.
The inspectors reviewed the licensee's evaluation of the event and
the corrective' actions taken to assure against recurrence as required
The corrective actions included
-incorporation of the lessons learned from the event into the site
specific training for contract HP technicians.
Some of the lessons
learned included recognizing a non-routine task for which a special
RWP is necessary, recognizing a situation where the creation of
airborne activity is likely and respiratory protection will always be
required, and emphasizing to contract HP supervisory personnel the
need~ to request special RWP's for non-routine tasks.
The HP
technician and his immediate supervisor were formally counseled with
regard' to appropriate use of RWPs and procedure compliance.
The
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corrective actions- and evaluation appeared adequate to meet the
requirements of 10 CFR 20.103(b)(2).
No violations or deviations were identified,
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5.
Control of Radioactive Material and Contamination, Surveys, and
Monitorings(83750)
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a.
Area and Personnel Contamination
.
The licensee maintains approximately 105,000 square feet (ft2),
excluding containment, as radiologically controlled.
In 1988, nine
percent or approximately 9,800 fte was contaminated.
Since the
beginning of the outage, the contaminated area of the plant had
increased to approximately 15,000 ft.
Licensee representatives
stated that most of the increase in contaminated area was due to
laydown and storage areas for outage related equipment.
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The inspectors reviewed Personnel Contamination Events (PCEs) for
-1989 and the current refueling outage.
Licensee representatives
stated that the goal for 1989 was less than 400 PCEs. Through May 2,
1989, the licensee documented 281 PCEs.
As a measure to reduce the
number of PCEs, the licensee has recently instituted a program to
prohibit anyone from entering the RCA who had an instance of
contamination on the skin or clothing until the individual attended a
one-on-one coaching session with the Plant Manager or Superintendent
of HP.
The inspectors noted during the PCE review that the root causes of
!
many of the PCEs were not always listed or were not defined
sufficiently to trend performance in this area.
Licensee
representatives stated that HP was responsible for documenting PCEs,
but the reports were forwarded to the Human Performance Evaluation
Section (HPES) for evaluation.
Licensee representatives were not
knowledgeable of any adverse trends regarding PCEs other than the
number of PCEs to date. When interviewed, HPES personnel stated that
no provisions had been made to evaluate adverse trends.
The
inspectors discussed with licensee management the decline of the
previous trending program and stated that important performance
information was not available.
In the past, the licensee tracked and
trended PCEs to the extent that details, such as, the number of PCEs
involving the various types of poor radiological work practices and
contamination events that occurred in clean areas of the RCA were
identified,
As a result, corrective actions were developed for the
identified adverse trends.
Licensee management stated that they
would review the reestablishment of trending PCEs
(see
Paragraph 2.b).
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b. -
Monitoring.
The inspectors observed that HP technicians were involved in the
cleanup and close out of Unit 2 prior to returning the unit-to-power.
The inspectors interviewed HP personnel to determine the extent of HP
involvement in responsibilities for cleanliness (housekeeping) of the
RCA.
Most' of the approximately'six to eight HP technicians
'
interviewed stated. that they spent significant amounts of time in
cleaning up-areas.
The technicians indicat'ed _that they were being
held responsible for overall housekeeping in the RCA.
An HP
representative stated that when areas became too cluttered with tools
and waste during the job that a hold was placed on tk operation
until.the area'was cleaned. However, this practice be
,e a frequent
occurrence and pressures to complete work on schedule from management
.
resulted in decreasing - the holds placed on jobs / ares.
The HP
representative indicated that HP technicians were :too involved in
housekeeping and that_ job coverage was being diluted. As an example,
the forema'n stated that one of his technicians spent two hours on job
coverage-and_ ten hours on housekeeping in one shift. The inspectors
asked security to provide an -access _ tape of selected mechanicel
maintenance foremen entering containment during the outage as an
~ indicator of their involvement with the problem of cleanup during and
after operations.
The inspectors reviewed the data and noted out of
the six maintenance foremen listed, only two had been in either
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Unit 1 or Unit 2 containment during the outage (approximately 30-40
days).
Based on the inspectors review of the data and interviews
with HP personnel, the inspectors discussed with licensee management
the potential for diluting HP technician radiological coverage of
work ' in progress.
The inspectors stated that no events were yet
identified that had resulted in inadequate radiological coverage due
to. housekeeping responsibilities.
Licensee management stated that
they were aware of HP being under pressure due to the outage, but
were not aware of problems in the area of housekeeping.
c.
Radiation Detection and Survey Instrumentation
During area " tours, the inspectors observed the use of survey
instruments by HP personnel.
The inspectors examined calibration
stickers.on radiat;cn protection instruments in use and at various
areas throughout the plant.
Instrument use appeared to be in
accordance with standard practice and all instruments examined had
been calibrated.
6.
Program for Maintaining Exposure As Low As Reasonably Achievable (ALARA)
(83750)
10 CFR 20.1(c) states that persons engaged in activities under licenses
issued by the NRC should make every reasonable effort to maintain
radiation exposures ALARA.
The recommended elements of an ALARA program
are contained in Regulatory Guides 8.8, Information Relevant to Ensuring
that Occupational Radiation Exposure at Nuclear Stations will be ALARA;
_ _ _ _ - - .
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and 8.10, Operatingi Philosophy for. Maintaining Occupational Radiation
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Exposures ALARA..
a.
Goals and Objectives
During )this' inspection, Unit'l was in day 70 of its outage whi'e
Unit 2 was in the last week of its , outage. .. The estimated 1989-
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collective -dose. goal for the station was set at 994. ;erson-rem or
k
497 person-rem: per reactor.
' As of - April 30, 1989, the station's.
collective dose was 824 person-rem.- The inspectors reviewed the
estimated and actual collective dose data for Loth Unit 1 and Unit 2
refueling outages.,
The total estimated collective dose for the
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Unit 1 outage was set at 569 person-rem while the estimate for Unit 2
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was set'at 678 person-rem.
As of May 4, 1989, the actual collective
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- dose for the-Unit.1 outage was'159 person-rem and 628 person-rem for
Unit 2.
. It should be noted that the station's -annual goal was
estimated.to be exceeded by 253 person-rem (1,247 person-rem [ station
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outage estimate]. - 994 person-rem [ station goal]) due- to additional
scope and unplanned work. - - Some of the additional scope included -
in-service inspections, steam generator tube' plug removal and
replacement, replacement of Unit 2 reactor head, and ' removal and
replacement of small bore snubbers.
b.
- ALARA Suggestion Program
.The inspectors . observed that ALARA suggestions were encouraged and-
. solicited from all plant: employees.
The licensee provides cash
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- incentives on a quarterly basis to the individual who submits 'the
best ALARA suggestion that is adopted for action.
Based on a
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selective review of ALARA suggestions for the last several years, it
was quite apparent that the. licensee's ALARA suggestion program was
effective in soliciting suggestions.
The following provides a
sumary from 1983 to 1989 of ALARA suggestions received and accepted:
ALARA Suggestions
. Year
Received
Accepted
1983
55
34
1984
55
7
1985
23
5
1986
40
15
1987
32
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1988
75
24
1989(to4/13/89)
19
4
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The inspectors observed that, for the years 1983 to 1987, there were
approximately 20 ALARA suggestions that are still incomplete.
It
should be pointed out that many of those suggestions required
engineering reviews and/or significant resources to complete.
The
-licensee was actively tracking the incomplete ALARA suggestions via
the Monthly Station ALARA Committee Meeting Minutes and had
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' established a goal for 1989 to eliminate.the 1983 through 1987 ALARA
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suggestion backlog.
c.-
High Dose Jobs
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.The inspectors reviewed the estimated and actual collective dose data
for the various jobs with the potential for .high dose for both
' Units 1 and 2.
The inspector. discussed these jobs with'the Site
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.ALARA Coordinator. . Additionally, the inspectors compared the average.
collective dose for the outage high-dose jobs listed in Table ~3-3.of
NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power
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Plants:. . Study on High-Dose' Jobs, Radwaste. Handling
and ' ALARA .
Incentives, with currently available Unit 2 outage data. . . Some' of the
job. categories could not -be compared directly- since the licensee
classified some jobs- differently.
The .following ' table lists the job
,
' title and average collective dose for Westinghouse Pressurized-Water
. Reactors:as- summarized in NUREG/CR-4254 and compares them to the-
licensee's. actual collective dose used for the 1989 Unit 2 refueling
outage:
Table 1
CollectiveDose.-(man-rem)
' Job Title
North Anna (U2/1989)
1. Snubber, Hanger, and
Anchor Bolt Inspection
and Repair.
110
23
'2. Steam Generator Eddy.
Current Testing
50
65
3.-Reactor Disassembly /
Assembly
48
30-
-4. Steam Generator Tube
Plugging-
47
13
.5. In-Service Inspection
46
55
6. Plant Decontamination
45
13 (as of 5/3/89)
7. Primary Valve Maintenance
and Repair
30
46
8. Scaffold Installation /
Removal
30
8 (as of 5/3/89)
9. Reactor Coolant Pump
Seal Replacement
17
4
10. Steam Generator Manway
'. ,
Removal / Replacement
16
3
11. Secondary Side Steam
Generator Inspection /
Repair
11
11
12. Fuel Shuffle / Sipping and
Inspection
9
3
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13. Operations--Surveillance,
Routines, and Valve
Lineups
7
16 (as of 5/3/89)
14. Cavity Decontamination
6
8
15. Radwaste System Repair,
Operation, and Maintenance
5
5 (as of 5/3/89)
6
System Repair and
Maintenance
3
2
The following high-dose jobs performed by the licensee on Unit 2 were
not included in the jobs listed in Table 1:
'(1) Design Change
Package - Large Bore Snubber Removal (82 man-rem [ actual]) and (2)
Removal of Steam Generator Tube Plugs-(93 man-rem [ actual]).
The licensee was actively tracking the collective doses for all jobs
and had the capability to track which jobs were over the projected
amounts.
The licensee also tracked collective dose by department
(Health Physics, Maintenance, Operations, Nuclear Site Services,
Instrumentation / Chemistry,
Power
Engineering,
and
Quality
Assurance / Quality Control). The jobs which contributed to precluding
the. licensee from meeting its goal included:
activities; replacement of Unit 2 reactor head; removal / replacement
of small. bore snubbers; and steam generator tube mechanical plug
removal.
The inspectors also reviewed the licensee's criteria for pre-job and
post-job ALARA reviews.
These criteria were specified in HP-5.4.30,
ALARA Pre-job and Post-job Reviews, April 9,1987.
The pre-job
review criteria were as follows:
(a) less than 1 man-rem: normal RWP preparation
(b) greater than or equal to 1 man-rem:
pre-job ALARA review
performed under ALARA Coordinator prior to RWP issue
(c) greater than or equal to 10 man-rem:
above requirements and
approval by station ALARA Committee
(d) greater than or equal to 50 man-rem:
above requirements and
approval by both Station Manager and ALARA Coordinating
Committee
The post-job review criteria were as follows:
(a) less than 1 man-rem:
normal job close out process
(b) Perform a post-job review and in addition meet with cognizant
job supervisor when:
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(1) greater than or equal to 1 man-rem and exceeded projected
man-rem by 125%
(2) greater than or equal to 10 man-rem
(3) * RWP required two or more RWP ALARA evaluations
(4) * As ALARA Coordinator deems necessary
In addition,
(5). greater than or equal to 25 man-rem:
The station ALARA
Coordinator shall (1) prepare brief job summary and
post-job critique with responsible job supervisor and (2)
schedule Station ALARA Committee (SAC) review and approval
of post-job review and critique report. . The SAC shall (1)
review post-job summary ano critique; (2) review applicable
ALARA evaluation documents; (3) make comments and
recommendations as required;.and (4) obtain approval by SAC
Chai rman.
It was apparent that the licensee had a very good program established
for performing the necessary review of jobs involving significant
dose. - During this inspection, it was observed that only one post-job
review (replace flange gasket on Unit 2-RC-R0-2) had been completed.
Approximately 20 jobs requiring post-job reviews were remaining.
It
should be noted that the station was in a dual unit outage and,
tFtrefore, approximately twice the number of post-job reviews would
be required. The inspectors noted the potential backlog problem, and
indicated to the licensee that this area would be reviewed during
subsequent inspections.
No violations or deviations were identified.
7.
Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on May 5,1989.
The inspectors
summa.ized the scope and findings of the inspection, including the
violation and.IFI. The inspectors also discussed the likely informational
content of the inspection report with regard to documents or processes
reviewed by the inspectors during the inspection.
The licensee did not
identify any such documents or processes as proprietary.
Dissenting
comments were not received from the licensee.
During the exit interview, an apparent LIV dealing with an inadequate
survey resulting in unplanned dose to a worker was discussed.
Based upon
careful consideration and evaluation of the adequacy and timeliness of the
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licensee's corrective action for failure to make an adequate survey to
prevent recurrence of an event similar to the first event in which an
individual exceeded the station's quarterly whole body dose control value,
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it was determined that the LIV would be considered as another example of
an apparent violation of 10 CFR 20.201(b).
NRC management considered the
corrective action for the first example of exceeding the administrative
control value to be neither timely nor comprehensive. Licensee management
was notified of this decision by telephone on May 16,1989 (Paragraph
3.b.).
Item Number
Description and Reference
50-338/89-15-01
IFI - Develop system to track and
identify trends in the areas of:
RPRs,
PCEs,
TLD/SRD discrepancies, and
maintenance
rework
activities
(Paragraph 2.b).
50-338, 339/89-15-02
VIO - Failure to perform adequate
radiation surveys necessary to prevent
individuals from receiving an exposure
to
radiation above the station
administrative control value (two
examples) (Paragraph 3.b).
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